EHS Audits: Is Your Facility Prepared

An environmental health and safety (EHS) audit is a systematic, objective tool to assess regulatory compliance in the workplace. An audit usually involves a survey of the workplace to:

Identify what regulations apply to the facility.

Determine whether workers are adhering to environmental and workplace safety requirements or other corporate policies and procedures regarding compliance.

Assess methods used and systems currently in place to ensure compliance.

Audits may be voluntary or required. In a voluntary audit, environmental health and safety managers usually decide on their own that it would be advantageous to conduct an audit, either to evaluate compliance status, or to identify any suspected problems.

A mandatory audit, however, may be part of the settlement or an enforcement action between a governmental agency and a facility. The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) regularly include audit requirements in settlement agreements with facilities that have violated regulations.

Benefits of Audits

There are numerous benefits to an audit if it is properly conducted and acted upon. An audit can:

help to identify and correct compliance issues, which can improve workplace safety and help to reduce facility and personal liability.

serve as an educational tool.

increase awareness and understanding of environmental and safety regulations.

be an opportunity to demonstrate the facility’s commitment to compliance.

potentially identify ways to improve the efficiency and cost-effectiveness of the compliance program.

Workplace audits may be viewed favorably by regulatory agencies and criminal prosecutors. An audit completed thoroughly with proper follow-up can signal that the facility is making a good-faith effort to comply with applicable regulatory requirements.

Potential Drawbacks to Audits

Although audits provide definite benefits, there are some potential negatives. Before conducting an audit, be aware of the following:

An audit may uncover previously unknown problems, and the solution may not always be simple or inexpensive to implement.

Failure to correct problems identified in an audit can potentially lead to many more problems. Implementing corrective actions in a timely manner is an important part of conducting an audit. If problems are identified in an audit and nothing is done to correct them, this information may be used against the facility in future enforcement proceedings.

Consult with legal counsel to obtain further information about whether audit information must be disclosed to OSHA or EPA. OSHA and EPA do not, as a general rule, require disclosure of internal audit reports because these agencies do not want to discourage companies from self-auditing to improve environmental and/or safety compliance. However, there have been instances when the agencies have subpoenaed audit information during an investigation, using it against the facility.

Record Keeping

Documentation is essential to demonstrate compliance with OSHA and EPA regulations and requirements. After your facility’s safety and health plan has been implemented, the effectiveness of the control measures selected must be evaluated.

Having a record keeping system in place allows you to track proficiencies and deficiencies. Once identified, keeping records of the corrective actions for your deficiencies will help OSHA and EPA auditors see how your facility is trying to be in compliance with required regulations.

Making Audits Work for You

The benefits of workplace audits outweigh the negatives. Some important points to keep in mind to help make audits a consistent benefit to the facility include:

Research Areas to be Inspected

The inspectors should know the areas that will be inspected, the types of tasks being conducted and the accident record of the work area(s). This will entail a little research, but knowing those details will help the auditors have a better knowledge of the potential problems within the area.

Gather Necessary Equipment

Although it depends upon the area to be inspected, auditors should have the following items with them during an audit:

The types of items brought into the area will depend upon how in-depth the inspection will be, the type of equipment that is being inspected and the background of the inspector.

Ensure Adequate Inspector Training

Unless the individual conducting the inspection has a well-rounded background in the environmental, health and safety field, they may need training or education on regulations pertinent to the areas to be inspected. Reviewing the regulations will increase the inspector’s knowledge base and will probably enable him or her to observe more unsafe conditions or procedures.

Set Appropriate time for Inspection

Although spot audits of equipment and procedures are useful, it is helpful to arrange schedules when most of the equipment will be operating and when most workers will be in the immediate area. However, the inspection should be performed at a time and in a way that it does not interfere with the production process. Unless the point of the inspection is to observe whether those time periods generate more hazards than other time periods, avoid particularly heavy workflow periods.

Use Checklists

Creating a checklist of things to look for helps guide auditors through the inspection process and reminds them of all topics or points in the scope of the inspection. But, remember that checklists are by no means all-inclusive. Auditors should have paper or space on the form to write additional notes.

After the audit, ensure that the recommendations and implementation of solutions are shared with all managers, line supervisors and workers. Be sure that they understand what they are required to do and the reasons for any changes in job procedures. Organize team meetings, or meet with each affected employee individually to explain any new information.

The bottom line: Always look for hazards that threaten the environment, health or safety of your workers. Then, find the most efficient way to prioritize and control them.

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Karen

Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 100 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) trainer and hazmat technician. She also serves on the Blair County, Pa., LEPC and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenea@newpig.com.

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